Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 1 of 74 Page ID #:1
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`VENABLE LLP
`Sarah S. Brooks (SBN 266292)
`ssbrooks@venable.com
`2049 Century Park East, Suite 2300
`Los Angeles, CA 90067
`Telephone: (310) 229-9900
`Facsimile: (310) 229-9901
`
`Attorneys for Plaintiff Canon Inc.
`
`UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`
`CANON INC., a Japanese corporation,
`Plaintiff,
`
`v.
`NINESTAR TECHNOLOGY
`COMPANY, LTD., a New Jersey
`corporation; NINESTAR
`CORPORATION, a Chinese corporation;
`and NINESTAR IMAGE TECH
`LIMITED, a Hong Kong corporation,
`Defendants.
`
`Case No. 2:20-cv-8498
`
`PLAINTIFF CANON INC.’S
`COMPLAINT FOR PATENT
`INFRINGEMENT
`
`JURY TRIAL DEMANDED
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`310-229-9900
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`LOS ANGELES, CA 90067
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`COMPLAINT
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`

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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 2 of 74 Page ID #:2
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`Plaintiff Canon Inc. (“Canon”) brings this action for patent infringement
`against Defendants Ninestar Technology Company, Ltd.; Ninestar Corporation;
`and Ninestar Image Tech Limited (collectively, “Defendants”), and alleges as
`follows:
`
`The Parties
`Canon is a corporation organized and existing under the laws of
`1.
`Japan, having its principal place of business at 30-2, Shimomaruko 3-chome, Ohta-
`ku, Tokyo 146-8501, Japan.
`2.
`Canon is a leading innovator, manufacturer, and seller of a wide
`variety of laser beam printers, inkjet printers, copying machines, cameras, and
`other consumer, business, and industrial products.
`3.
`On information and belief, Ninestar Technology Company, Ltd.
`(“Ninestar Tech”) is a corporation organized and existing under the laws of the
`State of New Jersey, with its principal place of business located at 17950 East Ajax
`Circle, City of Industry, California 91748, and another place of business located at
`13875 Ramona Ave., Chino, California 91710.
`4.
`On information and belief, Ninestar Tech conducts activities via the
`Internet at least through its website ninestartechonline.com.
`5.
`On information and belief, Ninestar Corporation is an entity registered
`in China, with its principal place of business located at No. 3883, Zhuhai Avenue,
`Xiangzhou District, Zhuhai, Guangdong, China 519060.
`6.
`On information and belief, Ninestar Corporation conducts activities
`via the Internet at least through its website ninestargroup.com and through the
`websites of the other Defendants.
`7.
`On information and belief, Ninestar Image Tech Limited (“Ninestar
`Image”) is an entity registered in Hong Kong, with a registered address of 9/F Unit
`18, New Commerce Center, No. 9 On Lai Street, Shatin, Hong Kong, S.A.R., and
`with its principal place of business located at No. 3883, Zhuhai Avenue,
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`COMPLAINT
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`310-229-9900
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`LOS ANGELES, CA 90067
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 3 of 74 Page ID #:3
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`Xiangzhou District, Zhuhai, Guangdong, China 519060.
`8.
`On information and belief, Ninestar Image conducts activities via the
`Internet at least through its websites ggimage.com and ninestarimage.com.
`9.
`On information and belief, Ninestar Tech, Ninestar Corporation, and
`Ninestar Image are all related companies, under common ownership and control,
`and part of a common enterprise known as “Ninestar” or “G&G.”
`Jurisdiction and Venue
`This is an action for patent infringement arising under the patent laws
`10.
`of the United States, Title 35 of the United States Code. This Court has subject
`matter jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1338(a).
`11.
`This Court has personal jurisdiction over Ninestar Tech because its
`principal place of business is located in this judicial district, and over all
`Defendants because each has, directly or through intermediaries, committed acts
`within California giving rise to this action and/or has established minimum
`contacts with California such that the exercise of jurisdiction would not offend
`traditional notions of fair play and substantial justice.
`12. Venue with respect to Ninestar Tech is proper under 28 U.S.C.
`§ 1400(b) because it has committed infringing acts in this judicial district and has a
`regular and established place of business in this judicial district.
`13. Venue with respect to Ninestar Corporation and Ninestar Image is
`proper under 28 U.S.C. §§ 1391(b) and (c) because they do not reside in the United
`States and therefore may be sued in any judicial district where they are subject to
`the court’s personal jurisdiction, including here in this judicial district.
`Canon’s Patents-in-Suit
`14. On December 26, 2017, U.S. Patent No. 9,851,688 (the “’688
`patent”), titled “Electrophotographic Image Forming Apparatus, Developing
`Apparatus, and Coupling Member,” duly and legally issued to Canon as assignee
`of the inventors, Masanari Morioka, Shigeo Miyabe, and Takahito Ueno. A true
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`COMPLAINT
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`310-229-9900
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`LOS ANGELES, CA 90067
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`

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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 4 of 74 Page ID #:4
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`and correct copy of the ’688 patent is attached as Exhibit 1.
`15. On January 2, 2018, U.S. Patent No. 9,857,766 (the “’766 patent”),
`titled “Electrophotographic Image Forming Apparatus, Developing Apparatus, and
`Coupling Member,” duly and legally issued to Canon as assignee of the inventors,
`Masanari Morioka, Shigeo Miyabe, and Takahito Ueno. A true and correct copy
`of the ’766 patent is attached as Exhibit 2.
`16. On April 14, 2020, U.S. Patent No. 10,620,582 (the “’582 patent”),
`titled “Electrophotographic Image Forming Apparatus, Developing Apparatus, and
`Coupling Member,” duly and legally issued to Canon as assignee of the inventors,
`Masanari Morioka, Shigeo Miyabe, and Takahito Ueno. A true and correct copy
`of the ’582 patent is attached as Exhibit 3.
`17. On July 14, 2020, U.S. Patent No. 10,712,709 (the “’709 patent”),
`titled “Electrophotographic Image Forming Apparatus, Developing Apparatus, and
`Coupling Member,” duly and legally issued to Canon as assignee of the inventors,
`Masanari Morioka, Shigeo Miyabe, and Takahito Ueno. A true and correct copy
`of the ’709 patent is attached as Exhibit 4.
`18. On July 14, 2020, U.S. Patent No. 10,712,710 (the “’710 patent”),
`titled “Electrophotographic Image Forming Apparatus, Developing Apparatus, and
`Coupling Member,” duly and legally issued to Canon as assignee of the inventors,
`Masanari Morioka, Shigeo Miyabe, and Takahito Ueno. A true and correct copy
`of the ’710 patent is attached as Exhibit 5.
`19. Canon is the sole owner of the entire right, title, and interest in and to
`the ’688, ’766, ’582, ’709, and ’710 patents (collectively, “Asserted Patents”),
`including the right to sue and recover for any and all infringements thereof.
`20.
`The Asserted Patents are valid and enforceable.
`Defendants’ Infringing Activities
`21. On information and belief, Defendants are engaged in the business of
`manufacturing, using, selling, and/or offering to sell in the United States and/or
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`COMPLAINT
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`310-229-9900
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`LOS ANGELES, CA 90067
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 5 of 74 Page ID #:5
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`importing into the United States toner cartridges (hereafter, “Accused Products”)
`for printers, including toner cartridges for use in certain Canon and HP color laser
`beam printers, including but not limited to the following printers: Canon i-
`SENSYS LBP7010C, Canon i-SENSYS LBP7018C, HP LaserJet Pro 100 MFP
`M175nw, HP LaserJet Pro CP 1025, HP LaserJet Pro CP 1025nw, HP TopShot
`LaserJet Pro M275 MFP, HP Color LaserJet Pro MFP M176, HP Color LaserJet
`Pro MFP M176n, HP Color LaserJet Pro MFP M176fn, HP Color LaserJet Pro
`MFP M177, and HP Color LaserJet Pro MFP M177fw.
`22. Non-limiting examples of Accused Products sold by Defendants that
`infringe the Asserted Patents include those bearing the designations 126A, HP
`126A, CE310A, CE311A, CE312A, CE313A, NHCE310A, NHCE311A,
`NHCE312A, NHCE313A, 130A, HP 130A, CF350A, CF351A, CF352A, CF353A,
`NHCF350A, NHCF351A, NHCF352A, and NHCF353A.
`23. On information and belief, Defendants offer to sell and sell the
`Accused Products within this judicial district and elsewhere, including through
`Ninestar websites, such as ninestartechonline.com, ninestarimage.com,
`ninestargroup.com, and/or ggimage.com.
`24. On information and belief, Defendants have substantial affiliations
`with one another and are individually and collectively responsible and accountable
`for the manufacture, use, sale, and/or offer for sale in the United States and/or
`importation into the United States of Accused Products.
`25. On information and belief, Ninestar Corporation is the ultimate parent
`company of, and exercises full control over, Ninestar Image and Ninestar Tech.
`26. According to the website ninestarimage.com, Ninestar Corporation
`develops, manufactures, and sells toner cartridges, and “has established branches,
`warehouses and logistics platforms in Holland, USA, Italy, Malaysia and Japan.”
`Ex. 6.
`27.
`
`The website ninestarimage.com further describes Ninestar Image as
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`COMPLAINT
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`310-229-9900
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`LOS ANGELES, CA 90067
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`2049 CENTURY PARK EAST, SUITE 2300
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 6 of 74 Page ID #:6
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`“a sub-company of Ninestar Corporation,” and Ninestar Tech as “the United States
`branch” of Ninestar Image. Ex. 6; Ex. 7.
`28.
` The website ninestartechonline.com describes Ninestar Tech as a
`“global leading supplier of consumer imaging supplies” and a “wholesale
`distributor” of Ninestar imaging products to Ninestar Technology registered
`resellers. Ex. 8.
`29.
`The common enterprise of Ninestar is further evidenced by Ninestar
`Corporation and Ninestar Image sharing the same physical address in Zhuhai,
`China.
`The Accused Products often are sold in packaging having one or more
`30.
`distinctive features that identify Ninestar as the source of the Accused Products.
`31.
`For example, Defendants often include on the packaging of their toner
`cartridges an image of three penguins. An example of this can be seen in the
`below image obtained from ninestarimage.com. Ex. 9.
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`LOS ANGELES, CA 90067
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`6
`COMPLAINT
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 7 of 74 Page ID #:7
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`Shown below is a photograph of the packaging of an exemplary
`32.
`Accused Product, which includes the same image of three penguins.
`
`33. As another example, on information and belief, Ninestar Corporation
`has been certified by the International Imaging Technology Council as a
`Standardized Test Methods Committee (“STMC”) Compliant Company and has
`been issued Certification No. 8105. Defendants often include on the packaging of
`their toner cartridges an STMC logo with Certification No. 8105 to identify
`Defendants as the source of those toner cartridges.
`34.
`Shown below is a photograph of a portion of the packaging of an
`exemplary Accused Product, which bears the STMC logo with Certification No.
`8105.
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`VENABLE LLP
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`7
`COMPLAINT
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 8 of 74 Page ID #:8
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`First Cause of Action: Infringement of U.S. Patent No. 9,851,688
`35. Canon repeats and incorporates by reference the allegations of
`paragraphs 1-34 above, as though set forth here in their entirety.
`36. Defendants have directly infringed and are directly infringing the ’688
`patent by making, using, selling, and/or offering to sell in the United States and/or
`importing into the United States toner cartridges embodying the invention defined
`by one or more claims of the ’688 patent, including without limitation the Accused
`Products, without authority or license of Canon. More particularly, Defendants’
`manufacture, use, sale, and/or offer for sale in the United States and/or importation
`into the United States of at least the Accused Products infringes at least claims 1,
`4-8, 10, 13-17, 19, 21, 22, and 24-27 of the ’688 patent.
`37. Defendants also are indirectly infringing the ’688 patent at least by
`virtue of their inducement of direct infringement of that patent by customers who
`use Defendants’ Accused Products in at least the Canon and HP laser beam printers
`listed above. At the very latest, Defendants will be given notice of their
`infringement of the ’688 patent upon being served with or otherwise receiving this
`Complaint. On information and belief, Defendants knowingly induce customers to
`use their Accused Products, including, for example, by promoting them for use in
`specific printers and/or providing customers with instructions for using them in
`those printers.
`38.
`The following paragraphs 42-85 show how Defendants’ model
`NHCE310A toner cartridge, which is an example of an Accused Product, infringes
`independent claims 1, 10, 19, and 24 of the ’688 patent.
`39. Upon information and belief, the exemplary model NHCE310A toner
`cartridge shown herein is substantially the same as the other Accused Products in
`all relevant respects, and thus is representative of the Accused Products.
`40.
`The Court has not yet construed the meaning of any claims or terms in
`the ’688 patent. In providing these detailed allegations, Canon does not intend to
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`COMPLAINT
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`310-229-9900
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`LOS ANGELES, CA 90067
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 9 of 74 Page ID #:9
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`convey or imply any particular claim construction or the precise scope of the
`claims. Canon’s contentions regarding the construction of the claims will be
`provided in compliance with the case schedule, any applicable federal or local
`procedural rules, and/or any applicable orders.
`41. Canon contends that each element of each asserted claim is literally
`present in the Accused Products. If as a result of the Court’s constructions or other
`determinations one or more claim elements are not literally present, Canon
`contends that each such element is present under the doctrine of equivalents and
`reserves its right to provide more detailed doctrine of equivalents contentions after
`discovery, a claim construction order from the Court, or at another appropriate
`time.
`Infringement of the ’688 Patent by the NHCE310A Toner Cartridge
`42.
`The NHCE310A toner cartridge infringes claim 1 of the ’688 patent.
`43. Claim 1 of the ’688 patent recites: “An image forming apparatus
`cartridge comprising:
`(a)
`a casing;
`(b)
`developer contained in the casing;
`(c)
`a developing roller having an axis L1, the developing roller
`being rotatably supported in the casing to permit rotation about
`the axis L1; and
`a coupling member having an axis L2 and including (i) a first
`end portion operatively connected to the developing roller, (ii) a
`second end portion including at least one projection having a
`slanted surface with respect to a plane perpendicular to the axis
`L2, and (iii) a connecting portion connecting the first end
`portion and the second end portion,
`wherein, as measured along a line perpendicular to the axis L2,
`a maximum distance from the axis L2 to an outermost surface
`
`(d)
`
`(e)
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`9
`COMPLAINT
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 10 of 74 Page ID #:10
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`(f)
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`of the connecting portion is shorter than a distance between the
`axis L2 and the at least one projection, and
`wherein the coupling member is movable between (i) a first
`position in which a tip of the at least one projection is a first
`distance away from the developing roller as measured in the
`direction of the axis L1 and (ii) a second position in which the
`tip of the at least one projection is a second distance away from
`the developing roller as measured in the direction of the axis
`L1, wherein the first distance is greater than the second
`distance.”
`44. As shown in Figure 1-1 below, the NHCE310A toner cartridge is an
`image forming apparatus cartridge, also known as a toner cartridge.
`
`Fig. 1-1
`45. As shown in Figure 1-2 below, the toner cartridge has a casing, with
`developer contained within the casing.
`
`Fig. 1-2
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`46. As shown in Figure 1-3 below, the toner cartridge has a developing
`roller having an axis L1. The developing roller is rotatably supported in the casing
`to permit rotation about the axis L1.
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`10
`COMPLAINT
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 11 of 74 Page ID #:11
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`Fig. 1-3
`
`47. As shown in Figure 1-4 below, the toner cartridge has a coupling
`member.
`
`Fig. 1-4
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`48. As shown in Figure 1-5 below, the coupling member (shown removed
`from the cartridge) has an axis L2.
`
`Fig. 1-5
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`11
`COMPLAINT
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`LOS ANGELES, CA 90067
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 12 of 74 Page ID #:12
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`49. As shown in Figure 1-6 below, the coupling member has a first end
`portion, a second end portion, and a connecting portion connecting the first end
`portion and the second end portion. In an assembled cartridge (shown in Figures
`1-1 and 1-4 above), the first end portion is operatively connected to the developing
`roller.
`
`Fig. 1-6
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`50. As shown in Figures 1-7, 1-8, and 1-9 below, the second end portion
`of the coupling member includes at least one projection having a slanted surface
`with respect to a plane perpendicular to the axis L2.
`
`Fig. 1-7 (a slanted surface)
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`12
`COMPLAINT
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 13 of 74 Page ID #:13
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`Fig. 1-8 (another slanted surface)
`
`Fig. 1-9 (another slanted surface)
`
`51. As shown in Figure 1-10 below, as measured along a line
`perpendicular to the axis L2, a maximum distance from the axis L2 to an outermost
`surface of the connecting portion (annotated as Dmax) is shorter than a distance
`between the axis L2 and the at least one projection (annotated as Dprojection).
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`13
`COMPLAINT
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 14 of 74 Page ID #:14
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`Fig. 1-10
`
`52. As shown in Figure 1-11 below, the coupling member is movable
`between: (i) a first position in which a tip of the at least one projection is a first
`distance away from the developing roller as measured in the direction of the axis
`L1 (annotated as D1 in the left image); and (ii) a second position in which the tip of
`the at least one projection is a second distance away from the developing roller as
`measured in the direction of the axis L1 (annotated D2 in the right image), with the
`first distance (D1) being greater than the second distance (D2).
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`14
`COMPLAINT
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`LOS ANGELES, CA 90067
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`2049 CENTURY PARK EAST, SUITE 2300
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`VENABLE LLP
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`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 15 of 74 Page ID #:15
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`Fig. 1-11
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`The NHCE310A toner cartridge also infringes claim 10 of the ’688
`
`53.
`patent.
`54. Claim 10 of the ’688 patent recites “An image forming apparatus
`cartridge comprising:
`(a)
`a casing;
`(b)
`developer contained in the casing;
`(c)
`a developing roller having an axis L1, the developing roller
`being rotatably supported in the casing to permit rotation about
`the axis L1; and
`a coupling member having an axis L2 and including (i) a first
`end portion operatively connected to the developing roller, (ii) a
`second end portion including at least one projection, with the at
`least one projection including a surface that extends at an
`obtuse angle from an adjacent surface of the second end
`portion, and (iii) a connecting portion connecting the first end
`portion and the second end portion,
`wherein, as measured along a line perpendicular to the axis L2,
`a maximum distance from the axis L2 to an outermost surface
`15
`COMPLAINT
`
`(d)
`
`(e)
`
`1
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`18
`19
`20
`21
`22
`23
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`26
`27
`28
`
`310-229-9900
`
`LOS ANGELES, CA 90067
`
`2049 CENTURY PARK EAST, SUITE 2300
`
`VENABLE LLP
`
`

`

`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 16 of 74 Page ID #:16
`
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`(f)
`
`of the connecting portion is shorter than a distance between the
`axis L2 and the at least one projection, and
`wherein the coupling member is movable between (i) a first
`position in which a tip of the at least one projection is a first
`distance away from the developing roller as measured in the
`direction of the axis L1 and (ii) a second position in which the
`tip of the at least one projection is a second distance away from
`the developing roller as measured in the direction of the axis
`L1, wherein the first distance is greater than the second
`distance.”
`55. As shown in Figure 1-1 above, the NHCE310A toner cartridge is an
`image forming apparatus cartridge, also known as a toner cartridge.
`56. As shown in Figure 1-2 above, the toner cartridge has a casing, with
`developer contained in the casing.
`57. As shown in Figure 1-3 above, the toner cartridge has a developing
`roller having an axis L1. The developing roller is rotatably supported in the casing
`to permit rotation about the axis L1.
`58. As shown in Figure 1-4 above, the toner cartridge has a coupling
`member.
`59. As shown in Figure 1-5 above, the coupling member (shown removed
`from the cartridge) has an axis L2.
`60. As shown in Figures 1-5 and 1-6 above, the coupling member
`includes a first end portion, a second end portion, and a connecting portion
`connecting the first end portion and the second end portion. In an assembled
`cartridge (shown in Figures 1-1 and 1-4 above), the first end portion is operatively
`connected to the developing roller.
`61. As shown in Figures 1-12, 1-13, and 1-14 below, the second end
`portion includes at least one projection, with the at least one projection including a
`
`16
`COMPLAINT
`
`310-229-9900
`
`LOS ANGELES, CA 90067
`
`2049 CENTURY PARK EAST, SUITE 2300
`
`VENABLE LLP
`
`

`

`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 17 of 74 Page ID #:17
`
`surface (labeled first surface in the images below) that extends at an obtuse angle
`from an adjacent surface (labeled second surface in the images below) of the
`second end portion.
`
`Fig. 1-12 (a surface extending at an obtuse angle)
`
`Fig. 1-13 (another surface extending at an obtuse angle)
`
`17
`COMPLAINT
`
`1
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`17
`18
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`21
`22
`23
`24
`25
`26
`27
`28
`
`310-229-9900
`
`LOS ANGELES, CA 90067
`
`2049 CENTURY PARK EAST, SUITE 2300
`
`VENABLE LLP
`
`

`

`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 18 of 74 Page ID #:18
`
`Fig. 1-14 (another surface extending at an obtuse angle)
`
`62. As shown in Figure 1-10 above, as measured along a line
`perpendicular to the axis L2, a maximum distance from the axis L2 to an outermost
`surface of the connecting portion is shorter than a distance between the axis L2 and
`the at least one projection.
`63. As shown in Figure 1-11 above, the coupling member is movable
`between: (i) a first position in which a tip of the at least one projection is a first
`distance away from the developing roller as measured in the direction of the axis
`L1 (annotated as D1 in the left image); and (ii) a second position in which the tip of
`the at least one projection is a second distance away from the developing roller as
`measured in the direction of the axis L1 (annotated D2 in the right image), with the
`first distance (D1) being greater than the second distance (D2).
`64.
`The NHCE310A toner cartridge also infringes claim 19 of the ’688
`patent.
`65. Claim 19 of the ’688 patent recites “An image forming apparatus
`cartridge comprising:
`(a)
`a casing;
`(b)
`developer contained in the casing;
`(c)
`a developing roller having an axis L1, the developing roller
`being rotatably supported in the casing to permit rotation about
`the axis L1;
`
`18
`COMPLAINT
`
`1
`2
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`4
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`14
`15
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`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`310-229-9900
`
`LOS ANGELES, CA 90067
`
`2049 CENTURY PARK EAST, SUITE 2300
`
`VENABLE LLP
`
`

`

`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 19 of 74 Page ID #:19
`
`(d)
`
`(e)
`
`a rotatable member rotatably supported in the casing and
`operatively connected to the developing roller;
`a coupling member having an axis L2 and including (i) a first
`end portion connected to the rotatable member, (ii) a second
`end portion including at least one projection, and (iii) a
`connecting portion connecting the first end portion and the
`second end portion; and
`an urging member configured to move the coupling member
`with respect to the rotatable member,
`(g) wherein, as measured along a line perpendicular to the axis L2,
`a maximum distance from the axis L2 to an outermost surface
`of the connecting portion is shorter than a distance between the
`axis L2 and the at least one projection,
`(h) wherein the coupling member is movable between (i) a first
`position in which a tip of the at least one projection is a first
`distance away from the rotatable member as measured in the
`direction of the axis L1 and (ii) a second position in which the
`tip of the at least one projection is a second distance away from
`the rotatable member as measured in the direction of the axis
`L1, wherein the first distance is greater than the second
`distance, and
`wherein, in the direction of the axis L1, an outer end of the
`rotatable member is more remote from the developing roller
`than an outer end of the urging member is from the developing
`roller in the direction of the axis L1.”
`66. As shown in Figure 1-1 above, the NHCE310A toner cartridge is an
`image forming apparatus cartridge, also known as a toner cartridge.
`67. As shown in Figure 1-2 above, the toner cartridge has a casing, with
`
`(f)
`
`(i)
`
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`18
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`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`310-229-9900
`
`LOS ANGELES, CA 90067
`
`2049 CENTURY PARK EAST, SUITE 2300
`
`VENABLE LLP
`
`19
`COMPLAINT
`
`

`

`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 20 of 74 Page ID #:20
`
`developer contained in the casing.
`68. As shown in Figure 1-3 above, the toner cartridge has a developing
`roller having an axis L1. The developing roller is rotatably supported in the casing
`to permit rotation about the axis L1.
`69. As shown in Figure 1-15 below, the toner cartridge has a rotatable
`member rotatably supported in the casing and operatively connected to the
`developing roller.
`
`Fig. 1-15
`
`70. As shown in Figures 1-5 and 1-6 above, the toner cartridge has a
`coupling member having an axis L2 and including a first end portion, a second end
`portion, and a connecting portion connecting the first end portion and the second
`end portion. As shown in Figures 1-7, 1-8, and 1-9 above, the second end portion
`includes at least one projection. As shown in Figure 1-16 below, the first end
`portion is connected to the rotatable member.
`
`20
`COMPLAINT
`
`1
`2
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`15
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`23
`24
`25
`26
`27
`28
`
`310-229-9900
`
`LOS ANGELES, CA 90067
`
`2049 CENTURY PARK EAST, SUITE 2300
`
`VENABLE LLP
`
`

`

`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 21 of 74 Page ID #:21
`
`Fig. 1-16
`
`71. As shown in Figure 1-17 below, the toner cartridge has an urging
`member configured to move the coupling member with respect to the rotatable
`member.
`
`Fig. 1-17
`
`72. As shown in Figure 1-10 above, as measured along a line
`perpendicular to the axis L2, a maximum distance from the axis L2 to an outermost
`surface of the connecting portion is shorter than a distance between the axis L2 and
`the at least one projection.
`
`21
`COMPLAINT
`
`1
`2
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`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`310-229-9900
`
`LOS ANGELES, CA 90067
`
`2049 CENTURY PARK EAST, SUITE 2300
`
`VENABLE LLP
`
`

`

`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 22 of 74 Page ID #:22
`
`73. As shown in Figure 1-11 above, the coupling member is movable
`between: (i) a first position in which a tip of the at least one projection is a first
`distance away from the developing roller as measured in the direction of the axis
`L1 (annotated as D1 in the left image); and (ii) a second position in which the tip of
`the at least one projection is a second distance away from the developing roller as
`measured in the direction of the axis L1 (annotated D2 in the right image), with the
`first distance (D1) being greater than the second distance (D2).
`74. As shown in Figure 1-18 below, in the direction of the axis L1, an
`outer end of the rotatable member is more remote from the developing roller than
`an outer end of the urging member is from the developing roller in the direction of
`the axis L1. As can be seen in the figure, the outer end of the urging member is
`inside of the rotatable member.
`
`Fig. 1-18
`
`The NHCE310A toner cartridge also infringes claim 24 of the ’688
`
`75.
`patent.
`76. Claim 24 of the ’688 patent recites “An image forming apparatus
`cartridge comprising:
`(a)
`a casing;
`
`22
`COMPLAINT
`
`1
`2
`3
`4
`5
`6
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`15
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`24
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`26
`27
`28
`
`310-229-9900
`
`LOS ANGELES, CA 90067
`
`2049 CENTURY PARK EAST, SUITE 2300
`
`VENABLE LLP
`
`

`

`Case 2:20-cv-08498 Document 1 Filed 09/16/20 Page 23 of 74 Page ID #:23
`
`(b)
`(c)
`
`(d)
`
`(e)
`
`developer contained in the casing;
`a developing roller having an axis L1, the developing roller
`being rotatably supported in the casing to permit rotation about
`the axis L1;
`a rotatable member rotatably supported in the casing and
`operatively connected to the developing roller;
`a coupling member having an axis L2 and including (i) a first
`end portion connected to the rotatable member, (ii) a second
`end portion including at least one projection, and (iii) a
`connecting portion connecting the first end portion and the
`second end portion; and
`an urging member configured to move the coupling member
`with respect to the rotatable member,
`(g) wherein, as measured along a line perpendicular to the axis L2,
`a maximum distance from the axis L2 to an outermost surface
`of the connecting portion is shorter than a distance between the
`axis L2 and the at least one projection,
`(h) wherein the coupling member is movable between (i) a first
`position in which a tip of the at least one projection is a first
`distance away from the rotatable member as measured in the
`direction of the axis L1 and (ii) a second position in which the
`tip of the at least one projection is a second distance away from
`the rotatable member as measured in the direction of the axis
`L1, wherein the first distance is greater than the second
`distance, and
`wherein at l